IR 05000397/1980016
| ML17275A848 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 11/03/1980 |
| From: | Haynes R, Toth A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17275A842 | List: |
| References | |
| 50-397-80-16, NUDOCS 8103030811 | |
| Download: ML17275A848 (22) | |
Text
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NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION V
Report No'.
50-397 80-16 Docket No.
License No.
CPPR-93 Safeguards Group Licensee:
P. 0.
Box 968 Richland, Washington 99352 Facility Name:
Washin ton Nuclear Pro ect No.
WNP-2)
Inspection at:
WNP-2
. ite Benton Count Washin ton Inspection conducted:
Ada Inspectors:
A". D. Toth, Serai Resident Inspector
~ I Iz/a Date Signed Date Signed Approved By:
R.
C.
Haynes,
-Nef, Reactor Projects Section Reactor Construction and Engineering Support Branch Summary:
Ins ection on Se tember 1-30 1980 Re ort No. 50-397 80-16)
Date Signed I ~ l.~ la Date Signed
~il d:
R ii, di i i:i f ii d
t activities to re-evaluate and improve detailed work methods at the WNP-2 site.
The inspection involved 85 inspector-hours on-site by the NRC resident inspector.
Results:
One item of noncompliance uas identified relative to reporting under
CFR 50.55(e).
(Paragraph 12 - failure to report significant construction deficiency).
RV Form 219 ('P)
sxosos04h
DETAILS 1.
Persons Contacted a
~
Washin ton Public Power Sup
S stem oW. C.
R. G.
'*R. T.
L. G.
R.
M.
R.
M.
G. I.
C.
R.
- J P
A.
M.
B. A.
C.
W.
Bibb, Project Manager Matlock, Managing Director's Office Johnson, Project Quality Assurance Manager Garvin, Nanager Quality Assurance Engineering Foley, Engineering Director Tanner, Project Construction Manager Wells, Deputy Project Manager, Construction Edwards, Principal Quality Assurance Engineer Thorpe, Quality Assurance Engineer Sastry, Owner's Quality Assurance Manager Holmberg, Change Manager Cardwell, Project Director at WBG
- b.
ci Burns and Roe, Inc.
B8R)
H. Tuthill, Assistant Quality Assurance Manager G. Harper, Site Engineering flanager R. Carmichael, Quality Assurance Engineer R. Spence, Lead Quality Assurance Engineer - Documentation R.
Powe, Lead Quality Assurance Engineer - Audits W. Murphey, Senior Hanger Engineer
.
Johnson Controls Inc.
T. Bastyr, Senior Project Manager R. Swift, Quality Assurance Manager d.
WSH/Boecon/Geri WBG)
P. Garcia, Project Manager N. Houck, Project Engineering Manager T. Page, Quality Assurance Manager M. Mead, Quality Control Manager R. Clouse, Construction Manager P. Webster, Quality Engineering Manager e.
Pittsbur h-Des Moines Steel Com an F. Harrington, Project Manager T. Foley, Quality Assurance Manager
f.
Bonneville Power Administration BPA)
J. Lewis, Project Engineer g.
Bechtel Cor oration D. Johnson, guality Group (WNP-2)
- Denotes personnel present at weekly meetings held on September 12, 19, 26, 1980.
Denotes personnel present at meeting held on October 2, 1980.
Several personnel at all levels of management and staff of the WBG and BAR organizations were also interviewed regarding activities in progress.
2.
Pro ect Personnel During this period the licensee made further personnel and organization changes in the effort to evaluate and improve the control of quality affecting activities.
Of the WPPSS personnel assigned to the mechanical contractor as project directors in July, two have been reassigned.
The cur rent assignees are:
C.
W. Cardwell, Project D. C. Timmins, Engineering R.
M. Tanner, guality Control A.
M. Sastry, formerly project director for quality assurance, was reassigned to a new position in charge of the three WPPSS task forces established to review contractor quality programs and ascertain the quality of completed wor k.
R.
M.
Foley, formerly project director for engineering, returned to his position as WPPSS project engineering manager.
R. Snaith, of Burns and Roe at New York, has. been temporarily assigned to WBG as a liaison representative.
Within the mechanical contractor organization the quality assurance policy authori ty of the joint venture has apparently been shifted from the Howard S. Wright Company to Boecon.
The Director of guality Assurance for Boeing Engineering and Construction (M. Thompson)
has assumed responsibility for quality assurance of the WBG joint venture at WNP-2.
Mr. Thompson has made gA organizational changes, including establishment of an Audit and Systems Analysis function with S.
Y. Young, Manager.
The WPPSS Task Force II established two positions under the Task Force Coordinator (T. A. Gross).
These are:
M. Clinton, Phase I Supervisor F. Damerval, Phase II Supervisor (Bechtel)
-3-Bechtel Corporation signed a contract with NPPSS for a study of the type of management assistance to be provided.
Some Bechtel employees have been assigned to supplement MPPSS/B8R manpower.
The following Bechtel personnel have been on-site since mid-September:
D. Stoker, Project Manager T. iMangelsdorf, Special Assistant E. Felton, Construction E. Goitein, Engineering J.
Laspa, Project Control D. Johnson, Quality G. Collins, Startup Additional Bechtel personnel assigned to the Quality group include:
M. Jacobson, C. Headrick and T. Fallon.
3.
~P'
t The labor dispute continued through September.
MPPSS stop work orders to all contractors for safety related work remained in effect.
Some reinspection and nondestructive testing activities were performed during September.
The ASME Section XI preservice inspection contractor, LHT, has been measuring pipe wall thicknesses using ultrasonic techniques.
The inspector requested the licensee to provide information regarding procedure and personnel reviews of this contractor.
This information will be reviewed during a subsequent inspection.
(397/80-16-01)
4, Licensee Action on Previous Ins ection Findin s
(Closed)
Unresolved Item (397/80-15-01):
Items 3f and 3g of the licensee's February 13, 1980 reply to concerns of Nr.
C.
E. Eschels were examined.
Item gf involved a hanger which reportedly was welded to )oth the containment shell and a radial beam at the 512'levation/azimuth 158
.
The hanger is not at this location and the licensee has not located such a hanger.
However, the licensee stated that the architect-engineer s design guidelines provide for" such an installation.
The inspector examined a relevant Burns
Roe engineering memorandum of February 19, 1980 to hanger design engineers which established thermal gradient and flexibilityguidelines for such designs.
The inspector had no further questions.
Item 3g involved anchorage of snubbers RRC-SA-3 and RRC-SA-4 to the containment shell and their possible attachment to unreinforced skin plates.
The architect-engineer's engineers evaluated the question and confirmed that hanger RRC-SA-3 is heavily reinforced from behind the skin plate, and RRC-SA-4 transfers its load directly to a structural column.
The engineers documented that these details are shown clearly on the approved structural drawings.
The inspector had no further question WPPSS Task Force II - Review of Contractor Work Nethods The licensee established a task force (Task Force II) to assure that site contractors are properly prepared to restart work and to engage in completed work reverification inspections/reviews.
Part of this task force's charter is to review contractor work methods including procedures, personnel qualifications, and training.
Site contractors are currently performing procedure changes, training program and other gA program improvements prior to submitting their work methods to the task force for review.
These contractor efforts are apparently in response to the WPPSS reply of July 17, 1980 to the NRC
CFR 50.54(f) request for information.
Task group reviews are often delayed pending completion of the contractor initiated changes.
The inspector noted that the task group reports therefore may not reveal the extent of previous problems since the problems may have been corrected
- by the contractors prior to the task force reviews.
The inspector informed the licensee project and gA management that these contractor efforts and any significant findings and corrective actions are of interest to the NRC and should be included in the bimonthly report to the NRC.
Task Force II initially reported to the site gA manager.
This month the task force shifted to report to the project manager through an overall task force manager.
This manager controls the three WPPSS task forces established in response to identified problems in the quality of contractor work.
A formal communication line from the Task Force Coordinator to the site gA manager was retained however.
WPPSS Task Force II - Reverification of Com leted Work The reverification efforts of this task force changed from that described in Attachment I of the licensee's reply to the NRC 10 CFR 50.54(f) letter.
This task force was to examine completed work and records, related quality and work procedures, and qualifications of key personnel.
Since the mobilization of the task force, the contractors are performing records reviews and reinspections.
Additionally, the contractors have been simplifying/revising their work and quality control procedures and upgrading their training programs.
Thus, for the purpose of controlling future work, the task force has become involved in the review of contractors'evised procedures.
The Burns and Roe/WPPSS site quality assurance group also review these procedures for quality assurance provisions.
The pre-task force gA review system prescribes specific reviews and methods for resolution of comments.
The task force effort introduces a new review function not covered in the gA review system.
Furthermore, the task force has identified various problem areas, some of which have project wide implications, and these findings have been communicated by memoranda to the Burns and Roe/WPPSS site quality assurance group.
However, the task force has not been provided with a methodology for documentation and tracking of these findings and associated corrective actions.
A provision for mandatory response to such task force items, similar to the audit finding or corrective action report systems, has also not been establishe h
At the October 2, 1980 management meeting, the project gA manager informed the inspector that this need has been recognized and an appropriate management policy/procedure is in preparation.
The inspector observed a draft of this document.
Implementation of this control will be examined following issuance of the document.
(397/80-16-02)
7.
Procedures Review Baseline a.
Architect-En ineer S ecifications Task Force II determined that the contractor's internal reviews of procedures and their own review of such procedures were based on out-dated architect-engineer specifications.
This problem appeared to have been caused by the following:
-1)
An accurate index of effective dates of each page of'
specification was not available.
The architect-engineer's practice is to revise and issue individual pages of specifications; thus an accurate index is required.
The WPPSS corporate gA auditor confirmed in audit No.80-168 (September 19, 1980) that such an index was unavailable and that various copies of the specification in use at the site contained outdated and super seded pages.
2)
An accurate index of effective Project Engineering Directives (PED's)
was not available.
These directives often modify parts of specifications and must therefore be available and usable to site personnel.
3)
Before the introduction of the PED as a change document, other change documents were used, e.g.,
Requests for Information-RFI, Contract Waiver Requests
-
CWR.
Some of these still apply and may not have been incorporated into the specifications or subsequent PED's.
The applicability of each of these other change documents was not defined.
The inspector noted that the licensee is taking steps to correct these document control matters.
gA Audit Findings and Corrective Action Requests have been issued to Burns and Roe.
Meanwhile, procedure and documentation reviews have been proceeding.
The licensee informed the inspector that when updated indices are issued, the changes will be identified and taken into account in the completed procedure reviews.
The inspector stated the mechanics of such accounting would be examined during subsequent inspections.
(397/80-16-03)
b.
Safet Anal sis Re ort Commitments The inspector determined that responsibilities were not clearly established for assuring that Safety Analysis Report (SAR) commitments were included in procedure revisions currently under review.
The SAR is not generally available to the contractor because contractors use the Burns and Roe specifications as their basic documents.
In the case of the mechanical contractor, procedures are being simplified and revised to incorporate requirements of those codes
-6-and standards delineated in the applicable specifications.
Where the specifications include provisions beyond the codes and standards, these are identified and submitted to Burns and Roe as recommended specification changes.
Task Force II has generated checklists to control their reviews of procedures.
These include an item regarding incorporation of the SAR requirements.
The Task Force Coordinator provided each team leader with a copy of the SAR section dealing with NRC Regulatory Guides and assured that a copy of the SAR is available to the reviewers.
Additionally, Task Force II requested Engineering Oepartment assistance for the review of specifications and procedures for inclusion of SAR requirements.
The WPPSS QA manager subsequently informed the inspector that actions were being taken to assure an adequate review of contractor procedures relative to SAR requirements.
The inspector observed a draft of the review plan on October 2, 1980.
Since many contractor procedures are in late stages of preparation, and some have already been reviewed by Task Force II, it appears that additional reviews will be required.
The WPPSS QA Manager noted that he did not expect these reviews to impact on the'rocedures significantly.
The system for performing these reviews will be examined in a subsequent inspection.
(397/80-16-04)
c.
Previous NRC Ins ection Findin s
The mechanical contractor had obtained copies of previous NRC inspection reports on September 30, 1980.
These were provided to Boecon corporate office reviewers to determine lessons learned and commitments to the NRC regarding QA program procedures and wor k methods.
Some of the commitments involved procedures currently being revised.
The inspector stated that the previous procedure changes and commitments need not necessarily be retained, in view of the extensive review process currently in process.
However, these changes and commitments should not be deleted without assuring that the associated lessons learned are encompassed by the new procedures and work methods.
The licensee informed the inspector that the previous commitments would be considered in the reviews.
This matter will be reviewed in subsequent inspections.
(397/80-16-05)
8.
ualifications and Trainin of Personnel The WNP-2 project did not include in its preliminary safety analysis report a specific commitment to NRC Regulatory Guide 1.58 nor its referenced standard ANSI-N45.2.6 for construction. activities.
The final safety analysis report, Amendment No.
8 dated February 1980, commits to this standard except for the formal certification method delineated in the standard.
The inspector determined that Task Force II prepared review checklists for assuring that contractor training/certification procedures for QC inspectors comply with the 1978 edition of ANSI-N45.2.6.
Since
H
preparation of the checklists, however, the HPPSS gA manager issued instructions on September 18, 1980 to Task Force II describing the type of information which must be included in contractor training procedures, but did not define the minimum acceptance criteria for inspector education and experience.
The requirements of ANSI-N45.2.6 are not imposed but WPPSS is studying the feasibility of imposing this standard on site contractors.
gualification requirements for personnel inspecting new work and re-inspecting previous work will be reviewed during a subsequent inspection.
(397/80-16-06)
9.
Mechanical Contractor Status-WBG By the end of September, the mechanical contractor had designated
individual task forces to work on general problems and to prepare for restart of wor k on specific construction installation activities.
A gA program
- review task headed by P. Webster was established as a separate effort and is factored in the plans for restart of work.
Although reviews are not yet complete, the gA program review task force determined that none of their findings so far would delay repair of the sacrificial shield wall (SSW)'orizontal weld.
Meanwhile, procedures have been tentatively approved within HBG for the SSW work and are being submitted to the licensee.
The gA program reviews have identified several problems which have been communicated to those tasks forces responsible for preparation of various procedure revisions.
However, final documentation of these findings and recommended corrective actions has not been completed and reviewed by management.
The gA program review considers corrective action reports, audit findings, findings documented in NRC inspection report No. 397/
80-08, and other such items.
Problem areas identified to date include inadequate procedures for: as-built program, processing of corrective actions, grouting, soils testing, concrete, hold point verification, material traceability, temporary material control, pipe weld end preparation and pipe wall thickness control, purchase order control, and torque wrench control.
In addition, the procedure review task forces have confirmed several cases where the procedures and the Burns and Roe specification do not comply with applicable ASME codes.
The mechanical contractor has been compiling lists of these discrepancies and submitting the lists to WPPSS for review and action.
10.
Containment Liner and Hetwell Retrofit Contractor'Status-PDM The inspector reviewed the status of PDM's recent actions concerning evaluation of work methods and corrective actions.
In February, 1980 the licensee determined that significant quality problems existed within the PDM program (ref. letters, HNP2 PDM-213A-F-80-082 dated 15 February 1980, and PDM WNP2-213A-CM-80-050 dated 21 February 1980).
PDM assigned a
new site gA Manager (T. Foley) and WPPSS assigned a Project gA Coordinator (H. M: Lazear) to provide increased attention on the problems and related
-8-corrective actions.
These actions included disposition of outstanding audit findings and nonconformance reports and reviews of documentation by a PDM task force which was established on April 29, 1980 (ref. letter, PDM WNP2-213A-CM-80-140).
Discrepancies relating to PDM activities included uncontrolled welding to the containment shell (e.g., temporary attachments),
missing heat numbers/drawing numbers/welder identification/magnetic-particle inspection reports and similar traceability aspects, by-passed hold points, and gC acceptance of welds with visually rejectable conditions.
PDM stopped work on March 21, 1980 and April 4, 1980 on penetration stiffening and pipe supports and other work in the containment wet well because of documentation traceability discrepancies and rework associated with the corrective actions.
The licensee established a hold point on
- restart of this work.
There has been close involvement of the PDM corporate gA manager in the review and analysis of the corrective actions.
The PDM gA manager expanded the task force effort to 8 task forces, each engaged in documentation reviews and reinspections.
Detailed checklists were developed for the reviews.
PDM also established a procedure review committee to streamline existing procedures and incorporate the WPPSS task force findings.
Working instructions for the committee were documented (September 11, 1980 company correspondence from the PDM Project Engineer).
The above activities were initiated by WPPSS and PDM as a result of events prior to WPPSS establishing the task forces in response to NRC's
CFR 50.54(f) letter.
Instrumentation Contractor Status - Johnson Controls JCI)
The inspector reviewed the status of JCI's current actions concerning evaluation of work methods and corrective. actions.
In June 1980, the contractor found several record irregularities in weld data sheets signed by one gC inspector.
The contractor's project manager then issued a
stop work directive calling for removal of all quality class I drawing packages from the field for review.
The contractor's field engineers are now reviewing these documents.
On August 26, 1980 the inspector observed poor welds on pipe supports in a storage area.
These supports were then inspected by the JCI gA organization who determined that all of the approximately 2000 pipe supports should be inspected at the site.
So far, about 300 have been reinspected in storage areas and reinspection of installed supports has not begun.
Installed supports will also require reinspection for thread engagement of HDI (Hilti drop-in) concrete anchors, a matter identified by 8&R auditor k
The inspector interviewed the JCI QA manager concerning this contractor's trend analysis of installation surveillence reports (ISRs).
Of approximately 1200 such reports, 174 are still open.
The QA manager demonstrated that he was currently performing some analysis of the open items.
JCI procedure QAS-1601-H2 was being revised to include a two-day time limit for replies to ISR's.
The QA manager stated that the JCI work procedures were being rewritten and simplified, and that the training program was rewritten.
This activity was undertaken by JCI in advance of the WPPSS Task Force II review of JCI's program.
The inspector observed JCI memoranda dated August 21 and 29 which identify engineering and construction personnel versus applicable work procedures in matrix form.
The memoranda include forms for the employees to certify that they read the procedures applicable to their work.
This program remains to be reviewed by WPPSS Task Force II.
12.
Licensee Re orts to NRC Under
CFR 50.55 e
By letter dated August 17, 1978 Westinghouse notified Burns
& Roe that the seismic qualification tests for the Westinghouse switchgear did not assume rigid conduit connections at the top of the equipment (switchgear, unit substations and motor control centers).
This is the manner in which the equipment was installed in the field.
Burns
Roe notified the licensee of this item on July 5, 1979 (letter BRWP-79-348).
This letter indicated that the situation was "being addressed under Potential Reportable Deficiency Investigation No. 79-4" and noted a need for an
"extended program (24 months minimum)" of additional seismic testing or physical modification of the equipment to assure its acceptability as installed.
Subsequent WPPSS correspondence (WPBR-79-418, dated October 10, 1979) indicated that in-situ testing would be performed to supplement analyses to qualify the equipment.
This letter indicated a high probability of success to qualify the equipment.
A subsequent WPPSS status report (F-80-38, dated January 4, 1980) discussed
"Potentially Reportable
CFR 50.55(e)
Conditions" including item No. 47 (79-4), and noted that Myle Laboratories had been selected to perform limited in-situ tests in the first quarter of 1980.
The inspector interviewed the WPPSS site QA Manager regarding the results of the in-situ tests performed in September, 1980.
The inspector was informed that preliminary reviews of the data indicate that the as-built status is acceptable.
However, the inspector informed the licensee that this item should have been reported to the NRC according to 10 CFR 50.55(e).
In particular, as of July 5, 1979, the licensee was aware that the switchgear was not installed consistent with its seismic qualifications and may not meet the operability requirements during design basis seismic events.
Furthermore, the licensee was aware that extensive evaluation would be required to determine the adequacy of the equipment.
The failure to notify and report this matter to the NRC appears to be contrary to the requirements of
CFR 50.55(e).
(397/80-16-07)
-10-13.
Mana ement Meetin The inspector met with the MPPSS project manager and the site gA manager on October 2, 1980 to discuss the inspector's findings and to discuss the NRC involvement in release of work for parts of the mechanical contractor's activities.
The on-site role of the NRC inspector and organizational communications were als'o discussed.
The licensee personnel indicated that personnel and records at all levels of the licensee and contractor organizations were open to the inspector; the inspector affirmed that he had encountered no hinderance to his inquiries.
The licensee expressed interest in having all of the inspectors concerns identified to the project gA manager to assure followup action by proper site personnel.
The inspector stated that the weekly meetings with the gA manager are a forum for discussing such inspection findings.
Such meetings were conducted September 12, 19 and 26, 1980 and October 3, 1980.
The project, manager stated that resolution of quality problems is a pre-requisite to plant operation, and confirmed that work restart and schedules are being planned accordingly.
The hlPPSS program is oriented toward evaluating certain work activities on a priority basis to permit work to restart in these areas so that construction progress may resume as soon as practical.
Currently there are 43 such activities defined, involving several of the site contractors.
Later, llPPSS will initiate its program of reinspections of previously completed wor ~
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